According to the 7th Circuit Judges in the case of the United States vs. Murphy and Baker:

Footnote 1 The trial transcript quotes Ms. Hayden as saying Murphy called
her a snitch bitch “hoe.” A “hoe,” of course, is a tool used for
weeding and gardening. We think the court reporter, unfamiliar
with rap music (perhaps thankfully so), misunderstood Hayden’s
response. We have taken the liberty of changing “hoe” to “ho,” a
staple of rap music vernacular as, for example, when Ludacris
raps “You doin’ ho activities with ho tendencies.”